BBVA

The role of the administrative, management and supervisory bodies

BBVA's Corporate Governance system

The Sustainability governance model is integrated into BBVA's corporate governance system. BBVA has a corporate governance system, made up of a set of principles, rules and mechanisms that integrate and regulate the structures and operation of its corporate bodies. This System is configured, mainly, by the provisions of the Statutes, the regulations of its different corporate bodies and the general policies of the Bank approved by the Board of Directors.

Board of Directors

One of the main elements of BBVA's Corporate Governance system is the Board of Directors, which, as the highest body of representation, administration, management and oversight, performs both the functions of management of the Entity and those of supervision and control of management.

As of December 31, 2024, BBVA's Board of Directors comprises 15 members, two of whom were executive and 13 are non-executive directors. BBVA's Board of Directors has a balanced composition, with high levels of independence and diversity, both with regard to the presence of men and women and the different types of directors, capabilities, experience and knowledge.

At the close of the 2024 fiscal year, BBVA's Board of Directors comprises 46.66% women and 53.34% men, meeting the target set forth in the Board of Directors' Selection, Suitability, and Diversity Policy.

In terms of independence, at the close of the 2024 fiscal year, BBVA's Board of Directors includes ten independent directors, representing 66.66% of the total Board members and 76.92% of the non-executive directors on the Board. In terms of nationality, the Board of Directors has a total of seven nationalities (Spanish, Turkish, Portuguese, Danish, American, Mexican and Belgian), with 40% of non-Spanish directors.

Functions and responsibilities of the Corporate Bodies

The Board of Directors shall have the powers established at any time by applicable legislation and the Bylaws. Among other functions, the Board of Directors has the power to approve the general policies and strategies of the Entity. The Board carries out, directly or through its Committees, the monitoring of the decisions adopted, including the supervision of the implementation of general policies, and the supervision of the management of the Company and its Group.

Governance model of the Corporate Bodies in matters of sustainability

Within the context of the Group's general management and control framework, the Board of Directors has incorporated Sustainability as one of the Bank's strategic priorities, as reflected in the Group's Strategic Plan for the years 2019-2024.

The Board of Directors has approved the General Sustainability Policy, which defines and establishes the general principles and management and control objectives and guidelines that the Group must follow in terms of sustainable development.

The Corporate Bodies promote that Sustainability, which includes environmental, social and governance aspects (ESG), is integrated into all the Group's businesses and activities, from a global perspective, and that the material impacts, risks and opportunities arising from it are adequately managed.

The Bank has a Global Sustainability Area, which is responsible for designing and promoting the execution of the Group's strategic Sustainability agenda and business development in this area; for establishing the Group's objectives in these matters; and for promoting and coordinating the Group's various lines of work in this area.

Board Committees

The Board of Directors has a structure of committees that assist it on matters within its competence:

• Executive Committee: supports the Board of Directors in decision-making and in the ongoing monitoring of BBVA's strategy and objectives in terms of Sustainability
• Risk and Compliance Committee: supports the Board in integrating Sustainability into the analysis, planning and management of the Group's financial and non-financial risks
• Audit Committee: supervises the process of preparing and the content of the information that must be formulated by the Corporate Bodies in matters of Sustainability for publication
• Appointments Committee: ensures that the competencies related to Sustainability are taken into account when analyzing the composition of the Board of Directors
• Remuneration Committee: analyses the selection and monitors the evolution of strategic indicators linked to variable remuneration, including indicators related to Sustainability
• Technology and Cybersecurity Committee: assists the Council in monitoring the technology strategy and managing cybersecurity

Knowledge, experience and capabilities of the Board of Directors

The Board of Directors has been strengthening its competencies in Sustainability, both through specific training and through the incorporation in recent years of directors with extensive experience and knowledge in Sustainability. The Board of Directors has an annual continuous training program, in which non-executive directors receive specific training on matters relevant to the exercise of their functions, including those related to Sustainability.

Specifically, during the 2024 financial year, some of the training sessions included in the training program of the Board of Directors dealt specifically with issues related to Sustainability.

Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies

Activity of the Corporate Bodies in the area of Sustainability

The Board of Directors has incorporated Sustainability as one of the Bank's strategic priorities and has approved the General Sustainability Policy. The Board of Directors has adopted other specific management decisions in the area of Sustainability, such as:

• The establishment of a strategic indicator for Sustainable Business Channeling, setting a target of 300 billion euros for the period 2018-2025
• Objectives for the decarbonization of the portfolio aligned with the goal of achieving net zero emissions by 2050
• The Investment in the Community of 550 million euros

Supervision and control processes

To supervise and control the execution of the decisions adopted by the Board of Directors in matters of Sustainability, the Corporate Bodies have reports received from both the Global Sustainability Area and the different areas of the Group, which incorporate Sustainability in the reporting of their businesses and activities.

These reports are submitted by the executive areas to the Corporate Bodies based on their competence, on a periodic or ad hoc basis.

In 2024, the Corporate Bodies have periodically received specific reports from the Global Sustainability Area, through which they have been able to monitor the different aspects of the strategy related to Sustainability and the objectives established in this area, as well as the main projects and lines of work of the Group in this area.

Likewise, the different business and global areas of the Group have reported to the Corporate Bodies on their activity, which includes Sustainability as one of its relevant pillars as it is a strategic priority of the organization, giving an account of the initiatives, projects and specific activities developed and the means available to them for the execution of this priority.

Most of the impacts, risks and opportunities derived from Sustainability that are of material importance to the Bank, listed in the "Double materiality analysis" chapter of this Report, have been reported to the Corporate Bodies throughout the year, either specifically or as part of broader reports from the different executive areas of the Bank on Sustainability matters.

Information model

BBVA's information model is characterized by providing the Corporate Bodies with information that is: complete, integral, adequate and consistent. The information model is made up of information from different sources that allows the directors to debate the issues submitted for their consideration within the corresponding Corporate Bodies and to carry out the functions assigned to them.

Directors have, prior to the meetings, the necessary information to be able to form an opinion on the issues that correspond to the Corporate Bodies, being able to request other information and advice that is required for the fulfillment of their functions, as well as request the Board of Directors for the assistance of external experts in those matters submitted to its consideration that, due to their special complexity or significance, so require.

Integration of sustainability-related performance in incentive schemes

Integration into variable remuneration for executive directors

BBVA has integrated sustainability indicators into the variable remuneration system. To promote the achievement of the objectives, the following are included in BBVA's variable remuneration system:

• Promoting new business through sustainability: Annual Variable remuneration linked to the promotion of sustainable business for all employees, including executive directors and Senior management of BBVA, as well as incentives linked to sustainable business specific to the commercial network.

• Achieving net zero emissions: since 2023, long-term variable remuneration has been linked to certain decarbonization targets for members of the collective, including executive directors and Senior management of BBVA.

Short-term incentive indicators (2024)

Long-term incentive indicators (2024)

Overall sustainability weight in remuneration

The indicators for calculating the annual variable remuneration include several non-financial or Sustainability-related indicators - NPS, Target Clients, Sustainable Business Channeling, Decarbonization of the Portfolio and Percentage of Women in Management Positions - which together represent 32.8% of the target annual variable remuneration.

Integration into financing structure

The issuance of own green, social and sustainable bonds plays a key role in achieving sustainability objectives. Business areas that issue products identified as green, social, and sustainable bonds under the applicable criteria receive a bonus, provided the financing cost of these types of bonds is lower than that of conventional bonds. This is determined by BBVA's Funds Transfer Pricing (FTP) system.

Statement on due diligence

Human rights due diligence

BBVA aims to contribute to the respect for Human Rights. This is why it frames this willpower in the Group's General Sustainability Policy and aligns it with its Code of Conduct. This policy is aligned with the International Bill of Human Rights, the Guidelines of the Organization for Economic Cooperation and Development (OECD) for Multinational Business, and the fundamental conventions of the International Labor Organization, among others.

Specifically, as provided in the General Sustainability Policy, the Group ensures compliance with all applicable laws and respect for internationally recognized human rights in all its relations with employees, customers, shareholders, suppliers and, in general, with the communities in which it conducts its businesses and activities.

Human Rights Due Diligence Process

Since 2018, the BBVA Group has carried out two global Human Rights Due Diligence exercises with the aim of preventing, mitigating and remedying potential impacts on human rights (such as human trafficking, forced labor, child labor, freedom of association and collective bargaining and, equal pay or discrimination).

Through it, BBVA has analyzed the following aspects:

• Identification of the main issues or potential impacts of operations
• Improvements within BBVA to try to prevent and mitigate these impacts
• The availability of channels and processes that facilitate grievance management

BBVA identifies the social and labor risks that arise from its activity in the different areas and countries in which it operates in order to manage the potential impacts generated, through the entity's ordinary risk management processes, or through standards and existing processes that integrate the human rights perspective, such as the Equator Principles.

ESG assessment and monitoring of customers

BBVA obtains ESG information from its customers and third parties to assess and monitor the ESG suitability of customers and deals.

Wholesale customers

BBVA assesses and monitors its wholesale customers under 4 dimensions:

• Their activities with special focus to those with potential negative environmental and social impact, covered under the Environmental and Social Framework
• Their transition risks leveraging on Transition Risk assessment tools
• Their behavior / controversies: Encompassed in the ESG controversies management procedure
• Their projects assessed under the Equator Principles

Environmental and Social Framework

The Environmental and Social Framework aims to establish criteria for the identification, assessment and monitoring of certain activities of the following sectors, selected for their high potential impact on nature and society: mining, agro-industry, energy, infrastructure and defense. The Framework identifies restrictions, either via prohibited activities or activities requiring special attention in these sectors.

BBVA, with the support of an independent advisor, analyses whether wholesale customers covered by its Framework do not engage in prohibited activities. It also analyses whether they engage in an activity requiring special attention, in which case BBVA assesses the environmental and social impacts derived from the activity to be financed.

Equator Principles

In 2004, BBVA signed the Equator Principles (EP), which establish standards for environmental and social risk management in project financing. Currently in their fourth version (EP4), these principles are applied globally in all industrial sectors.

In accordance with the EP, BBVA subjects each project under the scope of EP4 to an environmental and social due diligence analysis, considering impacts on environmental and human rights. Each deal is classified according to its risk level (categories A, B or C).

Regarding the human rights assessment and in accordance with the EP, BBVA requires due diligence on projects that may impact indigenous communities. In cases where this circumstance occurs, the free, prior and informed consent of these communities must be obtained, regardless of the geographic location of the project.

Legislative engagement

In 2024, BBVA has continued to take an active role in the field of future EU legislative initiatives, participating in the Working Groups on Sustainable Finance. BBVA contributes its opinion to the development of sectoral positions on various EU initiatives, including the work of dialogue and support with the European regulator in relation to the development of the directive on corporate due diligence in matters of sustainability.

Risk management and internal controls over sustainability reporting

ESG Reporting Committee

The Group has an ESG Reporting Committee. The Committee serves as a coordination and support body at executive level aimed at ensuring that the information to be disclosed on Sustainability matters that is to be formulated by the corporate bodies of the BBVA Group reflects the Sustainability objectives and strategy, risk management model and relevant quality standards.

The Committee is led by the Finance area and the following areas participate in it: Global Sustainability Area, Global Risk Management, Regulation & Internal Control, Legal Services, General Secretary, Data, Chair Office, Talent & Culture, and Internal Audit.

Verification of non-financial information

The information contained in the NFIS has been subject to a limited review by Ernst & Young Auditores, S. L., in its capacity as an independent verification services provider, with the scope indicated in its Verification Report which is included in the Appendix of this Management Report.

Risk management integration

The Risk and Compliance Committee supports the Board in integrating Sustainability into the analysis, planning and management of the Group's financial and non-financial risks, and in supervising their execution.

The Audit Committee supervises the process of preparing and the content of the information that must be formulated by the Corporate Bodies in matters of Sustainability for publication, as part of the public information of the Group.

Internal control processes

BBVA is constantly working on defining and adapting processes to ensure operational efficiency and adequate internal controls, including:

• The definition of solid criteria for classifying sustainable business
• Special attention to data quality
• The evaluation of non-financial risks
• The definition of mitigating measures

This process implementation is based on the integration of sustainability in the organization with a solid governance model and an identification and evaluation of aspects related to the sustainability of customers.

Data and estimates

In preparing the Consolidated Non-Financial Information Statement (NFIS), a series of estimates and assumptions has been made in various areas, including:

• Calculation of emissions
• Establishment and monitoring of transition objectives for portfolio alignment
• Estimation of the potential impacts of climate and environmental risks, as well as social and governance risks

These estimates have been made using the best information available as at December 31, 2024. The Group is pursuing various work streams to enhance the accuracy and reliability of the data. During the 2024 financial year, no significant changes have been made to the estimates from previous years.

Strategy, business model and value chain

BBVA Group's Value Chain

The ESRS consider that the scope of sustainability information extends beyond an entity's own operations and encompasses material impacts, risks, and opportunities throughout its value chain. This value chain comprises the activities, resources, and relationships that the entity employs and relies upon when defining its products or services, ranging from conception through to delivery, consumption, and end of life, across all the geographies in which it operates.

As a result of analysis, the BBVA Group's value chain has been categorized into three elements or phases:

Upstream

This phase includes entities that supply resources and provide services necessary for the development of the Group's activity. It primarily involves relationships with suppliers and partners for technology, information systems, legal or consultancy services, general supplies, among others.

Own Operations

This encompasses BBVA's own assets and internal processes that enable it to provide financial solutions, from product design and development to risk management. It also covers all BBVA Group companies and their employees.

Downstream

This refers to the phase in which BBVA markets and distributes its products and services to customers, as well as the monitoring of the effects those products and services generate in the broader environment. The Group identifies customers in its three main business segments, banking, insurance, and asset management, as the stakeholders involved in this phase of the value chain.

Business model and strategy

BBVA has defined sustainability as one of its six strategic priorities, covering the following three dimensions in the geographies where it operates:

1. Climate: Business opportunities related to global warming: electric transport, energy efficiency, renewable energy, etc.
2. Natural Capital: Business opportunities related to nature: water, land, biodiversity, and waste and pollution.
3. Inclusive growth: Business opportunities related to inclusive economic growth: inclusive infrastructures, financial inclusion, entrepreneurship, job creation, access to basic goods and services.

Strategic objectives

The execution of this strategy is based on the achievement of two main objectives:

1. Promoting new business through sustainability: Channeling 300 billion euros in sustainable business between 2018 and 2025, already achieved one year ahead of schedule with 304 billion euros channeled by 2024.

2. Achieving net zero emissions by 2050: With specific decarbonization targets for high-emission sectors and intermediate targets for 2030 for 11 sectors.

Additionally, BBVA has set itself the goal of contributing 550 million euros in social programs to benefit 100 million people between 2021 and 2025.

Business approach by customer segment

BBVA adopts a customized approach for each customer segment:

Wholesale customers (corporate and institutional)

• Sectoral solutions based on innovation and specialized knowledge
• Support in sustainability strategy implementation
• Offering sustainable products (bonds, loans, transactional banking activities)
• Preparation and monitoring of alignment plans with customers

Enterprise customers

• Simple and scalable solutions enabling economic savings (energy efficiency, fleet renewal)
• Consultation tools based on advanced data analytics
• Carbon footprint calculator for companies

Retail customers

• Customized digital solutions based on data analysis
• Focus on energy savings, mobility solutions, and financial inclusion
• Digital solutions accompanying customers throughout the entire process

Value creation approach

BBVA is promoting the creation of new business around sustainability with three priority areas:

1. Development of financial solutions: Promoting specialized solutions for customers to capture sustainability-related business opportunities
2. Differential risk management capabilities: Focusing on financing customer emissions reduction while leveraging competitive advantage in sustainability
3. Implementation of control processes: Ensuring operational efficiency and adequate internal controls, including solid criteria for classifying sustainable business

Interests and views of stakeholders

Main stakeholder groups

The General Sustainability Policy identifies BBVA's main stakeholders and other groups:

• Customers
• Employees
• Shareholders and investors
• Suppliers
• Regulators and supervisors
• Investment in the community

Stakeholder engagement approach

BBVA maintains a dialogue with customers based on:

• Sector knowledge of the implementation and execution of sustainability strategies
• Specialization in sectors that face the greatest challenges in the transition to a low-carbon economy
• Support in the analysis of the sustainability of the entire value chain of customers
• Offering sustainable products that meet financial needs and support transition
• Preparation and monitoring of alignment plans with customers

Customer engagement by segment

Wholesale customers

BBVA engages through:

• Development of sectoral roadmaps aligned with Paris Agreement objectives
• Analysis of value chain sustainability including carbon footprint of suppliers
• Dialogue on transition strategies and decarbonization plans

Enterprise customers

Engagement includes:

• Personalized dialogue adapted to sector, size, country and business maturity level
• Advisory tools such as carbon footprint calculator
• Training events with managers on sustainability solutions

Retail customers

BBVA engages through:

• Digital solutions for energy savings and sustainable mobility
• Financial inclusion initiatives for unbanked populations
• Education and awareness on sustainability issues

Industry and public sector engagement

BBVA has played an active role in various global initiatives for more than two decades, participating in:

Global initiatives:

• UN Global Compact
• Principles for Responsible Banking UNEP-FI
• Net-Zero Banking Alliance (NZBA)
• Partnership for Carbon Accounting Financials (PCAF)
• Task Force on Climate-related Financial Disclosures (TCFD)
• Task Force on Nature-related Financial Disclosures (TNFD)

Regional and sectoral engagement:

• Institute of International Finance (IIF)
• Association for Financial Markets in Europe (AFME)
• European Financial Services Roundtable (EFR)
• Spanish Banking Association (AEB)
• High Level Expert Group (HLEG) of the European Commission

Supervisory engagement

In 2024, BBVA has actively participated in working sessions with various supervisory bodies:

• European Central Bank (ECB)
• Bank of Spain
• Banking Regulation and Supervision Agency (BRSA) of Turkey
• Mexican authorities including the Bank of Mexico

Community investment

BBVA undertakes community investment programs and activities to address the most relevant challenges of the communities in which the Group is present, with the aspiration of creating opportunities for all.

The Group aims to invest 550 million euros in social programs to benefit 100 million people between 2021 and 2025, acting as an agent of social change alongside other stakeholders.

Material impacts, risks and opportunities and their interaction with strategy and business model

Material topics identified

BBVA has identified material impacts, risks and opportunities in four general topics:

1. Climate change
2. Own workforce
3. Consumers and end-users
4. Business conduct

Climate Change

Climate change is material for BBVA because it has significant effects both on the environment and on its own operations. This consideration aligns with BBVA's strategy, which integrates climate action as one of its fundamental pillars.

Material IROs for Climate Change:

Integration with strategy: The key role of banks in financing the transition to a decarbonized economy has been considered. BBVA can promote decarbonization and enhance customer resilience, generating value for both society and the Group.

Own Workforce

BBVA recognizes the importance of people as a fundamental pillar of its corporate strategy. The commitment to creating a positive work environment is material because employees contribute directly to achieving business objectives.

Material IROs for Own Workforce:

Consumers and End Users

Consumers and end users are fundamental to the Group's activity. Their satisfaction and financial security have direct impact on the Group's performance and reputation.

Material IROs for Consumers and End Users:

Business Conduct

Material IROs for Business Conduct:

Strategic integration

The results of the double materiality analysis are related to the definition of the Group's strategy and are consistent with various internal exercises to assess climate risks and non-financial risks. They reflect:

• Growing activity around sustainable business channeling
• Advances in digitalization
• Best practices in business conduct

The material IROs are concentrated in the downstream phase of the value chain, except for those related to corporate conduct and the Bank's own workforce, which fall under the Group's own operations phase.

Description of the processes to identify and assess material impacts, risks and opportunities

Double materiality analysis process

The Group has previously identified its sustainability-related matters based on international reference standards and best practices. In 2024, the double materiality analysis process has been updated to incorporate the principles of the CSRD and ESRS, as well as the implementation guide for the assessment of materiality issued by the European Financial Reporting Advisory Group (EFRAG).

The double materiality principle means that a subtopic is classified as material if it has a significant impact on people or the environment (impact materiality), if it significantly affects the financial position of the entity (financial materiality), or for both reasons.

The applied methodology has been structured into three phases: context analysis, identification and definition of IROs, and their subsequent evaluation.

Phase A: Context analysis

In the 2024 exercise, the context analysis has been reinforced to enhance the identification of potential material topics for the Group. This approach includes:

Internal documentation considered:

• Key policies (general sustainability policy, employee policies, supplier policies, corporate governance)
• Strategic documents reflecting the Group's commitment to responsible management

External information reviewed:

• Information from regulators and supervisory entities
• Essential regulations such as Climate Change Law and European guidelines
• Topics evaluated by leading ESG rating agencies (MSCI and Sustainalytics)
• Benchmarking against key industry peers

Environmental publications:

• Broad set of publications on biodiversity, climate change, and deforestation
• Market standards such as GRI and SASB

Phase B: Identification and definition of IROs

Building on the context analysis findings, BBVA has incorporated specialized tools:

Key tools used:

• UNEP-FI Impact Tool: to identify sectoral and geographic impacts from credit portfolios
• Human rights due diligence: facilitates identification of human rights-related impacts
• Climate Change Risk Assessment: provides comprehensive perspective in risk evaluation
• Reputational and Non-Financial Risk matrices
• Sector-specific standards such as SASB and European Banking Authority (EBA) guidelines

BBVA applies a perspective that acknowledges and addresses the interdependencies among IROs, for example, those tied to investments in carbon-intensive sectors.

IRO classification criteria:

• Actual/Potential: distinguishing between current IROs and those expected in the future
• Time Horizons:
  • Short-term: Up to 1 year
  • Medium term: From the end of the first year to four years
  • Long term: More than four years
• Value Chain Phase: upstream, own operations, and downstream
• ESRS Subtopic: allocation to subtopic categories defined by ESRS

Phase C: Evaluation

Impact materiality assessment

Impact materiality (inside-out perspective) assesses the positive or negative effects of the Group's activities on people, the environment and society. Assessment organized into two key axes: severity and probability.

Severity defined through three factors:

• Scale: Measures the relevance of the impact, from minimal effects to critical consequences
• Scope: Determines geographic or sectoral extent (local, national or global)
• Irremediable Character: Applied to negative impacts, assesses ability to reverse damage

Probability: likelihood of occurrence, measured on a scale from "unlikely" to "almost certain"

Materiality thresholds:

• Current impacts: materiality assigned to those with medium-high or higher severity
• Potential impacts: materiality applies to those combining medium-high severity with medium-high probability

Financial materiality assessment

Financial materiality (outside-in approach) evaluates effects on the Group's financial position, considering:

• Growth
• Operational performance
• Access to capital

Tools employed:

• ENCORE (Exploring Natural Capital Opportunities, Risks, and Exposure): identifies risks related to natural capital
• BBVA's Climate Risk Assessment: evaluates how climate risks could affect traditional risks
• SASB standards: provides metrics for assessing social and governance risks

Stakeholder involvement

During this process, the heads of each area actively participated, contributing with their expertise in identification, definition and evaluation of IROs. This multidisciplinary approach provided a comprehensive view covering all business segments and phases of the value chain.

The process has been developed taking into account the control and governance mechanisms established by the Group, including the management and supervisory bodies.

Dynamic process

The double materiality analysis must be understood as a dynamic process, subject to periodic reviews and adjustments as the entity's needs, strategic priorities, market conditions, dialogue with stakeholders, availability of new tools, adoption of emerging technologies and regulatory changes evolve.

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Material topics covered

Based on the double materiality analysis, BBVA covers the following ESRS topics in its sustainability statement:

1. ESRS 2 – General Disclosures: All applicable disclosure requirements
2. ESRS E1 – Climate Change: All applicable disclosure requirements for material climate-related impacts, risks and opportunities
3. ESRS S1 – Own Workforce: All applicable disclosure requirements for material workforce-related impacts, risks and opportunities
4. ESRS S4 – Consumers and End-users: All applicable disclosure requirements for material consumer-related impacts, risks and opportunities
5. ESRS G1 – Business Conduct: All applicable disclosure requirements for material business conduct-related impacts, risks and opportunities

Non-material topics

The following topics have been assessed as not material based on the double materiality analysis:

• ESRS E2 – Pollution
• ESRS E3 – Water and Marine Resources
• ESRS E4 – Biodiversity and Ecosystems
• ESRS E5 – Resource Use and Circular Economy
• ESRS S2 – Workers in the Value Chain
• ESRS S3 – Affected Communities

Legal framework and regulatory compliance

BBVA discloses non-financial information in line with the regulatory framework in force in Spain as of December 31, 2024, specifically:

• Law 11/2018 on non-financial information
• Law 7/2021 on climate change
• European Taxonomy regulation (Regulation (EU) 2020/852 and related delegated regulations)

The new regulatory framework regarding corporate sustainability information has come into force: Directive 2013/34/EU, as amended by Directive (EU) 2022/2464 (CSRD), and Delegated Regulation (EU) 2023/2772 developing the ESRS.

In the absence of transposition of the European directive, the CNMV and ICAC issued a joint statement recommending that sustainability information for 2024 should be published in accordance with the CSRD and ESRS, additionally including certain disclosures required by Law 11/2018.

Transition periods and exemptions

BBVA, in accordance with ESRS provisions, incorporates transition periods for some information requirements:

• Identification and disclosure of certain quantitative aspects relating to the value chain
• Anticipated financial effects concerning material impacts, risks, and opportunities
• Financial effects related to revenue from activities affected by physical and transition risks
• Specific characteristics of non-salaried workers
• Information concerning public or private protection programs for salaried workers

Content organization

The sustainability statement is organized in the following sections:

1. General information (ESRS 2 disclosures)
2. Environmental information (ESRS E1 – Climate Change)
3. Social information (ESRS S1 – Own Workforce, S4 – Consumers and End-users)
4. Information on governance (ESRS G1 – Business Conduct)
5. Complementary information including equivalency tables
6. Appendices with content tables for various regulatory frameworks

Verification

The information contained in the sustainability statement has been subject to a limited review by Ernst & Young Auditores, S.L., in its capacity as an independent verification services provider.

Reference to other standards

BBVA includes tables of equivalences and content references to other sustainability standards and frameworks, including:

• Responsible Banking Principles UNEP-FI
• ISSB (International Sustainability Standards Board)
• Transition plan equivalency table

Although these do not form part of the applicable legal framework, BBVA has deemed them relevant to include for stakeholder information.